Summary of United States v. Chadwick, United States Supreme Court, 1977. 

Statement of the Case:

The government is appealing a suppression of evidence in a drug distribution case when officers opened a locked footlocker back at the station, without a warrant or consent, and found marijuana inside it.

Procedure:

The trial court suppressed the evidence ruling that the officers should have obtained a search warrant before opening the footlocker.

Facts:

Chadwick and accomplice, Defendants, were carrying a heavy footlocker which was leaking talcum powder, material that is used to hide the odor of marijuana. The officers at Boston train station brought a dog and the dog signaled that there were narcotics in the footlocker.

As the defendants were loading the footlocker into the vehicle, the officers arrested them. Later at the police station, the officer broke the two locks which protected the footlocker and they discovered large quantity of marijuana.

Issue:

Whether officers violated the 4^th Amendment when they opened a locked footlocker back at the station, without a warrant or consent.

Procedural Result:

Judgment affirmed.

Holding:

Officers violated the 4^th Amendment when they opened a locked footlocker back at the station, without a warrant or consent.

Reasoning:

• The court ruled that the defendants had reasonable expectation of privacy in a closed container which was not part of a vehicle search, ie. the footlocker.
• The court further ruled that since the officers had no exigent circumstances.
• Closed containers, like the locked footlocker, deserve more protection than an open automobile, thus, the officers should have gained a warrant before opening the footlocker.
• A person’s expectations of privacy in a container are higher than a vehicle.
• The court ruled that 4th Amendment protects ‘people and not places’ and the search of the footlocker was unlawful.
• List of Reasons Expectations are lower in a vehicle than a container:
  • Function is transit and seldom serves as the repository of one’s personal effects.
  • Travels public areas and people can see inside.
  • States require that they are registered and details codes for its use.
  • Undergo official inspections.

Dissent:

• Agents probably could have avoided the footlocker search problem if they delayed the arrest and searched on the spot, instead of at the office.

Additional Points:

• Arkansas v. Sanders:  Officers had probable cause that a suitcase contained marijuana, and waited to stop the owner until he was driving in his car with it.  They searched it and found drugs.
  • Violated 4^th Amendment to search a container without a warrant just because it was inside a car.
  • Chadwick controlled here.
    
• United States v. Ross:  Officers had probable cause that a car contained narcotics, made a stop, and searched.  Found paper bag, looked inside, and found drugs.
  • The bag fell inside the automobile exception, since officers had probable cause to search a vehicle, not a container.
  • Bag would be permitted to be searched if the officers had a search warrant for the car, so it should be allowed when a warrantless search is constitutional